1.The registration fee of kes 20,000 should not be applicable to ICPAK members as they pay annual membership and practicing fees to their professional body.
2.Other professionals such as lawyers should only be registered as tax agents if they are also members of ICPAK for them to file returns for corporates (unless they only represent clients on legal aspects and engage ICPAK members on the financial part).

Qualifications necessary for Tax Agents should be administered under one professional body which happens to be ICPAK.
Registration should be done by Tax agents registration committee and not the commissioner.
The fee of Kes 20,000 is too high considering that the professional body is also charging membership fees.

An advocate of High court should if at all need to be considered should have background knowledge and understanding tax and accounts and be a members of ICPAK. Besides many have ICPACK membership. The twenty thousand fee is also not necessary so as to bring in more on board which - thus should be removed
altogether.

"a holder of any other relevant qualifications and experience recognized by the Commissioner as sufficient for a tax agent" - this would require such qualifications to be approved by ICPAK

Clarification on whether mere membership to ICPAK (and not having a practicing certificate) is the requirement for registration. The advocates require a practicing certificate.

3b&3c Tax is a product and those who are able by way of competence is the accounting process of drawing financial statements which is the bases of computing tax especially for Limited Companies would be the only ones qualifying to practice as such.
3d Relevant qualification is specific to the task, to my opinion;For one to qualify as a tax agent, tax knowledge should be paramount.

The registration fee should be scrapped or drastically reduced.

Advocates of the high court should be excluded because;

- Not all are very well versed with the tax laws

- The majority do not have a good grasp of accountancy. The tax returns that are submitted to KRA are as a result of financial statements. If they are not well done an advocate would not be able to pick it up and would end up giving wrong advice

- Former tax administrators should only be allowed to became agents only if they are members of ICPAK. There are some who do not fully understand the whole tax law due to the station they occupied during their tenure with the tax man.

Section 3(d) should be scrapped altogether as it is very ambiguous giving the commissioner too much power.

1) its purpose is to address unqualified and scrupulous operators and that is what it should do. Practising Members should be left alone to do their work